Privacy Policy

V 1.0, August, 2019

INTRODUCTION

Constellation Group (www.staging-bedataready.kinsta.cloud) is committed to keeping your information secure and managing it in accordance with our legal responsibilities under privacy and data protection laws where we operate.

This Privacy Policy provides information about how we process your name, email and any associated personal information we collect through our website and associated services. By visiting our website or using our services, you agree to your personal information being used and disclosed in the manner set out in this Policy. And stored on servers hosted with the European Union in accordance with GDPR requirements. In order to contact us, you must provide us with some basic personal information, including a valid email address. You do not have to provide any further personal information to us, but if you do not do so we may only be able to provide limited services to you.

We understand that your email and any associated personal information this is sensitive. We will never disclose or sell this information to any other party without your explicit consent. We may amend this Privacy Notice at any time by posting the amended version on our website (www.staging-bedataready.kinsta.cloud) including the effective date of the amended version. We will announce any material changes to this Privacy Notice on our website. It is your responsibility to keep up to date of any changes. Please notify us of any changes to your personal information which you have provided to us. You can do this by contacting us at info@staging-bedataready.kinsta.cloud

DEFINITIONS

As used herein, the following terms are defined as follows:

“Digital Asset” is a digital representation of value (also referred to as “cryptocurrency,” “virtual currency,” “digital currency,” “crypto token,” “crypto asset,” or “digital commodity”), such as bitcoin, XRP or ether, which is based on the cryptographic protocol of a computer network that may be (i) centralized or decentralized, (ii) closed or open-source, and (iii) used as a medium of exchange and/or store of value.

“Personal Information” or “Personal Data” or “your data” refers to any information relating to you, as an identified or identifiable natural person, including your name, an identification number, location data, or an online identifier or to one or more factors specific to the physical, economic, cultural or social identity of you as a natural person.

THE PERSONAL INFORMATION WE COLLECT

When using the Constellation Group, we may collect and use the following data about you:

Name;

Email address;

In addition to the terms set out within this general privacy policy, Constellation Group may collect additional personal information in accordance with the needs / specification of any contracts it may enter into. Such information requirements will be set out as part of the terms of the said contract.

INFORMATION WE COLLECT AUTOMATICALLY

When you use our services, as is the case with most websites, certain information will be collected by us automatically, including but not limited to:

Data about the pages you access;

Computer IP address;

Device ID or unique identifier;

Device type;

Geolocation information;

Computer and connection information;

Mobile network information;

Statistics on page views;

Traffic to and from the sites;

Referral URL;

Advertisement data;

Standard web log data;

HOW WE USE PERSONAL INFORMATION

We use the personal information collected from users for a number of purposes:

Personalising the look and feel of the website and its associated services (as well as our communications with you) to fit personal preferences which you have told us about or which we have inferred from your usage of our website.

Providing service update emails regarding the Constellation Group service and your specific account; and

Improving the service we offer – for example you may be asked to complete one of our online user satisfaction surveys.

We will only use your information where we have obtained appropriate permissions from you (e.g. with tick boxes) and will only use the information in accordance with this Policy, or where it is required and authorised by law.

YOUR CHOICES

Email Communications – Subject to applicable laws and regulations, we may from time to time send communications promoting services, products, facilities, or activities to you using information collected from you. We will provide you with an opportunity to opt-out of communications. We will never provide your Personal Information to third parties for direct marketing or other unrelated purposes without your written consent.

Cookies – You may decline session cookies if your browser or browser add-on permits but choosing to remove or disable our cookies may interfere with your use and functionality of the Constellation Group Service.

Right of Rectification– You have the right to correct any personal information we hold on you that is inaccurate, incorrect, or out of date.

Right of Erasure – You have the right to ask us to delete your data when it is no longer necessary, or no longer subject to a legal obligation to which Constellation Group is subject to.

Portability – You may have the right to transfer certain of your personal data between data controllers, for example, to move your account details from one online platform to another.

Location Information – You may be able to stop the collection of location information through your device settings or by following the standard uninstall process to remove our applications from your device; however, because such data is used by us to meet legal requirements, as well as for ongoing fraud and risk monitoring purposes, choosing to remove or disable location services may interfere with your use and functionality of the Constellation Group Service.

YOUR DATA CONTROLLER

Constellation Group is your data controller, and is responsible for the collection, use, disclosure, retention and protection of your personal information in accordance with this Privacy Policy, as well as any applicable national laws. Data is managed by amazon web services on data centers in the European Union. If you have any questions about how we protect or use your Personal Information, you can contact us at info@constellationgroup.io with the heading DPO.

KEEPING YOUR RECORDS

Your data is only accessed internally on a need to know basis, and it will only be accessed or processed if absolutely necessary. We keep records for as long as required to operate the service in accordance with legal, tax and accounting requirements. Where your information is no longer required, we will ensure it is disposed of in a secure manner and, where required by applicable law we will notify you when such information has been disposed of.

WHERE WE STORE YOUR PERSONAL DATA

Our operations are supported by a network of computers, servers, and other infrastructure and information technology, including, but not limited to, third-party service providers, such as amazon web services. We and our third-party service providers store and process your personal data in the European Union.

KEEPING INFORMATION SECURE

We invest resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure. However, no internet-based site can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is beyond our control. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data during transmission, and any acts of transmission are at your own risk.

COMMUNICATIONS FROM US

Where you have indicated you would like to receive updates we may send marketing in the form of email alerts and bulletins to tell you related to our products.

Where you have indicated that you would like to receive direct marketing communications from us, we will use your personal preferences which you have told us about, which we have derived from your service usage or market research.

You can also unsubscribe from receiving certain electronic messages or direct marketing by following the “unsubscribe” instructions included in our communications with you. Or by email emailing us at info@constellationgroup.io.

PROVIDING INFORMATION TO OTHERS

We work closely with a number of trusted partners with whom we need to share personal information to help us operate Constellation Group. Where required, these may include:

Law enforcement bodies in order to comply with any legal obligation or court order and, where we are otherwise requested to provide information, we may provide it but only in accordance with applicable privacy and data protection laws;

Analytics and search engine providers that assist us in the improvement and optimization of our site;

We may also provide information to third party service providers who process information on our behalf to help run some of our internal business operations including email distribution, IT services and customer services. We will only share information with such organisations where we have your permission to do so in accordance with this Policy, or where we believe it is necessary for a legitimate reason connected with the services we offer.

You agree that we may disclose or share your personal information with such third-party providers in order that we may operate Constellation Group as deemed necessary. These service providers and group companies may be located in the UK, other countries in the European Economic Area or elsewhere in the world. Different privacy laws may apply in these countries and you understand and unambiguously consent to the transfer of personal information to these countries, group companies and service providers.

In the event your personal information is transferred to a foreign jurisdiction, it may be subject to the laws of that jurisdiction and we may be required to disclose it to the courts, law enforcement or governmental authorities in those jurisdictions but we will only do so where required by applicable laws. By using Constellation Group, you consent to your Personal Data being transferred to other countries, including countries that have different data protection rules than your country. In all such transfers, we will protect your personal information as described in this Privacy Policy.

We do not maintain a published list of all of the third parties with whom we share your personal information with, as this would be heavily dependent on your specific use of our Services. However, if you would like further information about who we have shared your personal information with, or to be provided with a list specific to you, you can request this by writing to info@constellationgroup.io

ACCESS RIGHTS

You have the right to request copies of certain of your personal information within our custody and control, as well as the details of how we use that information. If you think any of the personal information we hold about you is inaccurate, you may also request it is corrected. You also have a right, in certain circumstances, to require us to stop processing your personal information.

In relation to all of these rights, please email or write to us at info@constellationgroup.io. In certain circumstances (for example where required or permitted by law) we might not be able to provide you with access to some of your personal information, but where appropriate we will notify you of the reasons for this.

PRIVACY WHEN USING DIGITAL ASSETS AND BLOCKCHAINS

The use of bitcoin, XRP, ether, and other Digital Assets, may be recorded on a public or private blockchain. Public/private blockchains are distributed ledgers, intended to immutably record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis which can lead to deanonymization and the unintentional revelation of private financial information, especially when blockchain data is combined with other data.

Because blockchains are decentralized or third-party networks which are not controlled or operated by Constellation Group or its affiliates, we are not able to erase, modify, or alter personal data from such networks.

PROTECTION OF MINORS

Constellation Group is not directed to persons under the age of 18, hereinafter “Minors” and we do not knowingly collect personal information from Minors. If we learn that we have inadvertently gathered personal information from a Minor, we will take legally permissible measures to remove that information from our records. If you are a parent or guardian of a Minor, and you become aware that a Minor has provided personal information to Constellation Group, please contact us at info@constellationgroup.io and you may request to exercise your applicable access, rectification, cancellation, and/or objection rights.

COOKIES

When you use Constellation Group, we may make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (herein, “Cookies”) on your computer or other devices used to visit Constellation Group’s website or services. We use Cookies to (i) help us recognize you as a customer, collect information about your use of Constellation Group to better customize our services and content for you. And (ii) to ensure that your account security has not been compromised by detecting irregular or suspicious activities.

We use both session and persistent Cookies. Session Cookies expire when you log out of your browser. Persistent Cookies remain on your computer or mobile device until deleted or otherwise expire. Most web browsers are set to accept Cookies by default. You are free to decline most of our session Cookies if your browser or browser add-on permits but choosing to remove or disable our Cookies may interfere with your use and functionality of the Constellation Group Service.

COMMUNICATIONS FROM US

Where you have indicated you would like to receive updates we may send marketing in the form of email alerts and bulletins to tell you related services.

Where you have indicated that you would like to receive direct marketing communications from us, we will use your personal preferences which you have told us about, which we have derived from your service usage or market research.

You can also unsubscribe from receiving certain electronic messages or direct marketing by following the “unsubscribe” instructions included in our communications with you.

UPDATES

We keep this Policy under regular review and make changes periodically. It is your responsibility to be aware of the content of this Policy. If you do not accept the amended Policy, please stop using our website.

THIRD PARTY SITES

This Policy only applies to the www.staging-bedataready.kinsta.cloud site. If you land on our site from other websites (or move to other sites from our website) you should read their separate privacy policies.

COMPLAINTS PROCESS

If you have a complaint about how we have handled your personal information you may contact us using info@constellationgroup.io and we will investigate your complaint.

CONTACT

If you have any questions about this Policy or would like to exercise your rights with respect to your personal information, please contact us via info@constellationgroup.io.